EIS for Proposed Modernization and Expansion of TBR

Appendix E

Preliminary Jurisdictional Determination

EIS for Proposed Modernization and Expansion of TBR

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UNITED STATES MARINE CORPS MARINE CORPS AIR STATION

BEAUFORT, SOUTH CAROLINA 29904-5001 IN REPLY REFER TO

5090 NREAO/116

12 May 2011

May 12, 2011

Mr. Donald W. Hendrix

Coastal Branch, Regulatory Division

United States Army Corps of Engineers, Savannah District

100 W. Oglethorpe Avenue

Savannah, Georgia 31401

Re: Request for Preliminary Jurisdictional Determination of Waters of the United States

for the Modernization and Expansion of Townsend Bombing Range, Georgia (SAS-

2010-01120)

Dear Mr. Hendrix:

The United States Marine Corps (USMC) is requesting a Preliminary Jurisdictional

Determination (PJD) of lands being acquired for the modernization and expansion of Townsend

Bombing Range (TBR) in Long and McIntosh Counties, Georgia. This request is pursuant to a

meeting attended by you, Mr. Jered Jackson of Naval Facilities Engineering Command Southeast

(NAVFAC SE), and Ms. Brenda Powell and Mr. Jonathan Oravetz of Ecology and Environment,

Inc. (E & E) on 15 February 2011 in Orange Park, Florida. The Proposed Action includes the

acquisition of up to 36,828 acres of land and construction in up to eight Impact Areas (IAs)

within the lands proposed for acquisition (see further discussion of the Proposed Action below).

Based upon the discussions on 15 February 2011 (summarized in your 18 February 2011

electronic mail sent to Mr. Jackson, Ms. Powell, and Mr. Oravetz) and information contained in

the “Public Notice for the Characterization of Jurisdictional Determinations: Purpose, Application

and Documentation Requirements as Defined by the Savannah District, United States Army

Corps of Engineers (USACE),” dated 4 March 2009 (March 2009 Public Notice), the USMC has

determined that a PJD will meet the needs of the Environmental Impact Statement (EIS)

documentation process. Per the March 2009 Public Notice, the USMC understands that if this

request is approved by the USACE, the PJD will be non-binding and will indicate the

approximate locations of waters of the United States pursuant to Section 10 of the Rivers and

Harbors Act of 1899 (RHA; 33 U.S.C. 403) and Section 404 of the Clean Water Act (CWA; 33

U.S.C. 1344).

The PJD will be used to describe the existing environment and to quantify impacts in the EIS

being prepared for the project. Prior to construction, when the specific engineering design has

been completed, the USMC anticipates that an Approved Jurisdictional Determination (Approved

JD) will be requested to assist in the permitting of the Proposed Action. The USMC understands

that an Approved JD will require delineation of waterbodies and wetlands that are subject to

CWA/RHA jurisdiction.

In order to prepare this enclosed request for a PJD, E & E conducted onsite field verification of

existing National Wetlands Inventory (NWI) data within the eight IAs and collected supplemental

wetlands data to support the location of wetlands and surface water bodies within these areas (see

“Methodology” section below). For all areas outside of the IAs, the published NWI boundaries

were used.

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This letter summarizes the methodology used to preliminarily identify, classify, and quantify

wetlands and surface waters located within the Acquisition Areas and IAs. In addition, this

submittal includes supplemental information requested on the PJD Form. Rather than reiterate

information requested on this form within the body of this letter, this form has been completed

and provided as Attachment A.

Summary of the Proposed Action

The Proposed Action includes acquisition of up to 36,828 acres within two areas (e.g.,

Acquisition Areas 1 and 3 [Note: A third Acquisition Area, Area 2, was originally considered as

part of the Proposed Action, but was subsequently dropped from consideration due to

environmental sensitivity.]) in Long and McIntosh Counties, Georgia, for the modernization and

expansion of TBR. As part of the Proposed Action, up to eight IAs would be placed within the

two Acquisition Areas (see Attachment B, Figure 1-1). Within the eight IAs, target infrastructure

and new roads would be constructed, and upgrades to existing roads would occur. Detailed

construction footprints for proposed infrastructure and roads within the IAs are not available at

this time. The IAs would also be subjected to airborne strafing and inert bombing exercises for

military training. Areas outside the IAs (but within the Acquisition Areas) would serve as safety

buffers. Except for constructing new roads and firebreaks, and upgrading existing roads and

firebreaks, the safety buffers would be managed to permit sustainable timber harvest where

applicable while maintaining and improving ecosystem function across the entire area.

Methodology

Data Sources

Prior to conducting any field work, the following data sets were obtained and reviewed:

United States Fish and Wildlife Service (USWFS) NWI wetland data (USFWS 2010);

Natural Resources Conservation Service (NRCS) soil survey data;

United States Geologic Service (USGS) Watershed data;

USGS topographic maps;

National Hydrography Dataset (NHD) data;

2010 true color aerial imagery; and

2009 infrared aerial imagery.

Method for Determining PJD Wetland Boundary and Surface Waters in Safety Buffers

Wetland boundaries and surface water in the safety buffers (e.g., all areas outside of the IAs but

within the boundaries of the Acquisition Areas [see Attachment B, Figure 1-1]) were determined

using the data sources listed above. The USFWS NWI data were used to identify the location,

classification, and wetland acreage calculations provided in the “Findings” section. GIS data from

the NHD and USGS topographic maps were used to determine existing surface waters in the

safety buffers. Wetland boundaries and surface water locations in the safety buffers are provided

in Attachment C.

Method for Determining PJD Wetland Boundary and Surface Waters Within IAs

Vegetation, soil, and hydrology data were collected in the field within the eight IAs to verify the

locations, classification, and wetland acreage calculations provided by the data sources listed

above. These results are provided in the “Findings” section. The USFWS NWI dataset and other

collected data were downloaded onto sub-meter accurate GPS units prior to field mobilization to

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assist in the effort. Field verification efforts resulted in modifications (i.e., expansion and

deletion) to the USFWS NWI boundaries in some areas.

Onsite data collection and field verification of the NWI was conducted within the eight IAs from

28-31 March 2011. Representative Wetland Determination Data Forms (WD Forms; see

Attachment D) were completed and wetland reference points were collected to aid in the

identification of wetland boundaries outside of, or differing from, the USFWS NWI data.

Wetland boundaries that differed from the USFWS NWI maps were digitized in GIS and tied

back into the existing USFWS NWI lines within the Acquisition Areas.

Surface waters observed within the IAs that were not identified on the USGS maps or by the

NHD were identified and digitized in GIS using aerial imagery.

Findings

Safety Buffers

The Acquisition Areas, most of which will serve as safety buffers, are located within the Atlantic

and Gulf Coastal Lowland Forest and Crop Region Land Resource Area and are located north of

the Altamaha River in Long and McIntosh Counties, Georgia. The areas are characterized as

having flat, nearly level topography, composed primarily of sedimentary rocks of marine origin,

and alluvial sediments generally sloping southeast toward the Atlantic (USGS 2004). Soil

information from the NRCS suggests a large portion of the area consists of hydric poorly-drained

soils (see Attachment E). The Acquisition Areas lie within the Altamaha (HUC [Hydrologic Unit

Code] #3070106) and Ogeechee Coastal Watersheds (HUC #3060204) (see Attachment F).

Most land in the Acquisition Areas is currently managed for silviculture. A majority of the area is

composed of densely planted loblolly pine (Pinus taeda) and extensive ditching is evident

throughout. Wetland environments are found within depressional, floodplain, and flow-way areas.

Wetlands documented by the USFWS NWI maps included emergent, shrub/scrub, forested, palustrine unconsolidated bottom, and palustrine unconsolidated shore. Most wetlands within the

Acquisition Areas show evidence of silviculture operations such as ditching, bedding, furrowing,

tilling, and clearing.

Impact Areas

Within the IAs, modifications to the USFWS NWI lines were made based upon field observations

and data collected during the March 28 - 31 survey period. The wetlands boundary and surface

water locations within the IAs are provided in Attachment G. WD Forms are provided in

Attachment D and photographs are provided in Attachment H.

Wetland environments observed in the IAs included emergent, shrub/scrub, and forested

wetlands. Vegetation within emergent wetlands consisted of broom sedge (Andropogon

virginicus var. virginicus), sugarcane plume grass (Saccharum giganteum), common fox sedge

(Carex stipata), Hypericum sp., dog fennel (Eupatorium capillifolium), wooly panicum (Panicum

scabriusculum), wire grass (Aristida stricta), hatpins (Eriocaulon sp.), wool grass (Scirpus

cyperinus) and saw grass (Cladium mariscus). These areas exhibited wetland hydrologic and soil

indicators such as standing water or high water tables, oxidized rhizospheres on living roots,

presence of crayfish burrows, and redox features within the soil.

Vegetation within shrub/scrub wetlands consisted of wax myrtle (Myrica cerifera), saltbush

(Baccharis halimifolia), titi (Cyrilla racemiflora), sweet gum saplings (Liquidambar styraciflua),

and blackberry (Rubus sp.) These areas exhibited wetland hydrologic and soil indicators such as

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water marks, saturation, moss trim lines, oxidized rhizospheres on living roots, thin dark surfaces,

and redox features within the soil.

Forested wetland were characterized by cypress (Taxodium sp.), red maple (Acer rubrum), sweet

gum, sweet bay (Magnolia virginiana), black gum (Nyssa sylvatica), water oak (Quercus nigra),

laurel oak (Quercus laurifolia), loblolly bay (Gordonia lasianthus), wax myrtle, Iris sp., chain

fern (Woodwardia sp.), fetter bush (Lyonia lucida), and arrow heads (Sagittaria sp.). These areas

exhibited wetland hydrologic and soil indicators such as water marks, saturation, moss trim lines,

oxidized rhizospheres on living roots, dark surfaces, muck presence, and redox features within the

soil.

IA 1: Additional wetland acreage was added to the USFWS forested wetland located at the

northwest corner of IA (see Attachment D, WD-01 and Attachment H, Photograph 1). Additional

wetland acreage was also added to the USFWS forested wetland in the north-central area of the

IA (see Attachment D, WD-02 and Attachment H, Photograph 2), and the USFWS scrub/shrub

wetland in the center of this IA.

IA 2: An extensive ditch system runs through IA 2. This ditch system was digitized and includes

the large surface water network located within the center of the IA (see Attachment H,

Photographs 3 and 4) and the two small surface waters located in the northeast corner of the IA

(see Attachment H, Photographs 5 and 6). Additional wetland acreage was added to connect a

depressional wetland to the large floodplain wetland that runs along the eastern edge of the IA

(see Attachment D, WD-03 and Attachment H, Photograph 7). Two depressional wetlands were

identified in the central portion of the IA, adjacent to the drainage ditch (see Attachment D, WD-

04 and Attachment H, Photograph 8). A third depressional wetland was identified at the northeast

corner of the IA (see Attachment D, WD-05 and Attachment H, Photograph 9).

IA 3: A large emergent wetland area was added to the central portion of the site (see Attachment

D, WD-06 and Attachment H. Photographs10 through 15). This emergent wetland was recently

harvested, had standing water, and was composed of broom sedge, sugarcane plume grass,

common fox sedge, and saw grass. A forested wetland was added in the south-central portion of

the IA to connect two NWI wetlands located to the north and south (see Attachment H,

Photograph 16).

IA 4: Three additional emergent wetland areas were added in the center of the IA. The large NWI

wetland that spans the central and southern portions of the IA was recently harvested (see

Attachment H, Photographs 17 through 19). A small depressional forested wetland was added

along the roadside that runs through the northeast corner of the site (see Attachment D, WD-07

and Attachment H, Photograph 20).

IA 5: Three emergent wetland areas were added (see Attachment H, Photographs 21 and 22),

representative of WD-06 (see Attachment D) These areas were recently harvested, had standing

water, and were composed of broom sedge, Hypericum sp., loblolly pine saplings, sweet gum,

and blackberry. A forested wetland was added in the northwest corner, as well as a depressional

forested wetland in the center of the IA. Three surface waters were added within this IA.

IA 6: Two surface waters were added on the east side of the access road. A small depressional

forested wetland was added in the northwestern corner while a portion of the NWI wetland was

removed from the northwest corner that ran adjacent to a north-south drainage ditch. This area

was a forested riparian buffer and did not exhibit appropriate wetland hydrology (see Attachment

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IA 7: A depressional forested wetland was added along 'the northern boundary at the center of the IA (see Attachment D, WD-08 and Attachment H, Photograph 24). Surface waters were previously mapped in the southern portion. Our observations extended them northwest to the comer of the IA. Additional surface water was added along the eastern boundary in a north-south direction (see Attachment H, Photograph 25).

IA 8: A portion of the NWI associated with the north-south drainage ditch was removed in the southeast quadrant of the IA (see Attachment H, Photograph 26). This area was a forested riparian buffer and did not exhibit appropriate wetland hydrology. Soils in this area were composed of fill material likely used in the construction of the drainage ditch. The extensive ditch network was digitized and included in surface waters for this IA.

The findings of efforts described above for the entire 36,828-acre proposed Acquisition Area, including the lAs, are summarized in Table I.

Table 1 Wetland and Surface Water Classification and Acreage

for Acquisition Areas Cowardin Class Symbol Acreage

Palustrine Emergent PEM 1,036.4 Palustrine Forested PFO 9,191.9 Palustrine Shrub/Scrub PSS 807.7 Palustrine Unconsolidated Bottom PUB 2.1 Palustrine Unconsolidated Shoreline PUS 5.3

Total Wetlands 11,043.4 Cowardin Class Symbol Linear feet

Riparian Lower Perennial Stream Bed R2SB 198,065.5 Riparian Intermittent Stream Bed R4SB 56,527.4

Total Surface Waters 254,592.9

A GIS file of wetlands and surface water boundaries presented in Table I that were determined to be jurisdictional waters of the U.S. within the combined 36,828-acre Acquisition Areas is provided in Attachment I. Included in the GIS files are attributes that describe wetland and stream type based on the Cowardian Classification System and data source information. Upon your concurrence of this PJD request, wetlands and surface waters identified in this GIS file will be used in the EIS to describe and quantify impacts to waters of the U.S.

We understand that USACE processes a PJD within 60 days from the time it deems the submittal to be complete. Please contact Jered Jackson at (904) 542-6308 or jered.jackson@navy.mil if you have questions regarding this submittal or require additional information to process this request. We look forward to obtaining the PJD and working further with the USACE, Savannah District Regulatory on this project.

Sincerely,

/)/J, W. A. DRAWDY Natural Resources and Environmental Affairs Officer By Direction of the Commanding Officer

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Environmental Affairs Officer

By Direction of the

Commanding Officer

Attachments

cc: John Conway, NAVFAC SE

Jered Jackson, NAVFAC SE

Brenda Powell, E & E

Jonathan Oravetz, E & E

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